Consultation Paper No 3 of 2020 – Electronic Transactions Regulations

CONSULTATION PAPER
NO. 3 OF 2020
ELECTRONIC TRANSACTIONS
REGULATIONS
15 September 2020

Consultation Paper No. 3 of 2020
Why are we issuing this paper?
The Abu Dhabi Global Market (ADGM) proposes to introduce regulations to facilitate electronic transactions, electronic records and electronicsignatures.ADGMhas issued this Consultation Paper to invite public feedback and comments on those regulations. Who should read this paper? The proposals in this Consultation Paper willbe of interest toADGMentities and investors, and those wishing to establish a presence in ADGM or otherwise doing business in ADGM, and their professional advisors. How to provide comments All comments should be in writing and sent to the address or email specified below. If sending your comments by email, please use the Consultation Paper number in the subject line. If relevant, please identify the entity you represent when providing your comments. The ADGM reserves the right to publish, including on itswebsite, any comments you provide, unless you expressly request otherwise at the time of making any comments. Comments supported by reasoning and evidence will be given more weight by ADGM. What happens next? The deadline for providing comments on this proposal is 14 October 2020. Once we receive your comments, we will consider whether any modifications are required to the proposed Electronic Transactions Regulations. TheBoard will then proceed to enact the Regulations. You should not act on any proposal in this consultation paper until the new regulations are issued. We will issue a notice on our website when this happens. Introduction

Consultation Paper No. 3 of 2020
Comments to be addressed to:
Consultation Paper No. 3 of 2020
Abu Dhabi Global Market
Abu Dhabi Global Market Square
Al Maryah Island
PO Box 111999
Abu Dhabi, UAE
Email: consultation@adgm.com

Consultation Paper No. 3 of 2020

1. Online contracting and the use of electronic signatures is now commonplace and many
   businesses are required to manage a vast quantity of electronic records. Although businesses and consumers are adapting to electronic dealings, legal concepts that have traditionally been based on the existence of a tangible or physical medium, such as an instrument, a document, an ‘original’ or a ‘signature’, still remain relevant in legislation and need to be considered in this changing environment.
2. ADGM often receives enquiries in relation to its legal position on electronic contracts and
   specifically the validity of electronic signatures. Currently, the law in ADGM addresses these matters in a limited manner, including certain protections under English common law around the formation of contracts adopted through the Application of English Law Regulations 2015 and under the Companies Regulations 2020 around the acceptance of documents delivered electronically. We recognise that there is scope for improvement to the current position, particularly in relation to electronic signatures and electronic contracts.
3. ADGM considers that the implementation of specific legislation regulating electronic dealings
   in ADGM would bring ADGM’s regulatory framework more in line with international best practice in relation to e-Commerce and electronic dealings. It would also provide greater certainty within ADGM in relation to the ability of parties to use electronic documents, retain electronic records and rely on electronic signatures.
4. To ensure ADGM develops legislation that is consistent with international best practice, ADGM
   has benchmarked the Regulations across a number of jurisdictions and found that many countries have based their legislation on the following instruments published by the United Nations Commission on International Trade Law:
   (a) the Model Law on Electronic Commerce (1996); (b) the Model Law on Electronic Signatures (2001); and (c) the Convention on the Use of Electronic Communications in International Contracts (2005), (together, the Model Law), while incorporating their own variations and modifications to best suit their individual jurisdiction’s needs.
5. Accordingly, the proposed Regulations are based on the Model Law.
6. The proposed Electronic Transactions Regulations (Regulations) are set out in AnnexA.
7. Unless otherwise defined, capitalized terms referred to in this paper have the meanings
   attributed to such terms as contained in the Regulations and the Interpretation Regulations 2015. Background

Consultation Paper No. 3 of 2020
8. Electronic transactions legislation has taken many different forms at the international and UAE
domestic levels. There are three main legislative approaches for dealing with signature and authentication technologies.
9. The first approach is the prescriptive approach. This approach imposes use of a specific
technology, typically digital signature technology. This approach has been adopted in many countries including the UAE, Argentina, Brazil, Colombia, South Africa, Japan, India and Russia.
10. The prescriptive approach requires a specific technical method for the electronic signing of
documents, and dictates the types of permissible signature technologies. Some prescriptive laws do not recognise an electronic transaction, unless the mandated technology is used.
11. The second approach is the two-tiered approach. This approach creates legal presumptions
in favour of one technology or method, but also admits other means of identification. This approach has also been adopted in many countries including Italy, Germany, Finland, Spain, France, Ireland, Hungary, Norway, UK, Singapore and Thailand.
12. Many European countries follow the two-tier approach. This approach accepts all or most
electronic signatures on a technology-neutral basis, but also creates a class of approved technologies similar to the prescriptive approach. While these laws may dictate a specific process to create digital signatures, most of the countries which followthis approach also allow parties to agree between themselves what is an acceptable form of signature.
13. The third approach is the minimalist approach. This approach provides minimum
requirements and leaves the parties free to choose the signature method they deem appropriate. This approach has been adopted in countries including Australia, Canada, New Zealand, USA and the DIFC.
14. Considering the specific characteristics of ADGM and in particular its common lawjurisdiction
with principles-based legislation and regulatory approach, together with innovation focus, ADGM believes following the ‘minimalist’ approach is the most suitable approach to follow. This approach has been adopted by other leading common law jurisdictions as referred to above. Under the minimalist approach, electronic signatures are considered to be the functional equivalent of handwritten signatures, provided that the technology employed is intended to serve certain specified functions and, in addition, meets certain technology-neutral reliability requirements. Such an approach is also consistent with the explanatory note of the Model Law, which warns against prescribing certain technologies, as technology itself is ever developing and changing.
15. The proposed Regulations aim to remove any potential legal obstacles in relation to electronic
dealings within ADGM, by providing for the equivalent treatment for users of paper-based documentation and users of electronic information. The Regulations are intended to be a framework that is permissive in nature, rather than proscriptive, giving the parties the freedom to choose the electronic methods they deem appropriate. In other words, the framework does Approach and structure of the Regulations

Consultation Paper No. 3 of 2020 not attempt to set out rules covering every aspect of electronic transactions. In addition, adopting the minimalist approach will provide the legal clarity and comfort that is sought by ADGM entities and, importantly, will maintain and promote the ease of doing business in ADGM, by:
(a) facilitating rather than over-regulating electronic transactions; (b) adapting existing legal requirements to the requirements of electronic commerce while allowing for technological advances; and (c) providing for basic legal validity of electronic transactions and providing increased legal certainty. Q1: DO YOU HAVE ANY COMMENTS ABOUT THE PROPOSAL TO ADOPT A MINIMALISTIC APPROACH IN THE REGULATIONS? Electronic Signatures
16. While section 39 of the Companies Regulations 2015 provides that a document is executed by
a company “if it is signed on behalf of the company”, the section is neutral and does not express the form that the signature may take; that is, it does not specify that the document must be ‘in writing’, or how it can be provided.
17. However, Rule 12, Part 3 of the ADGM Courts Procedure Rules 2016 provides a clearer
position as follows:
“12. Signature of documents
Where any of these Rules or any practice direction requires a document to be signed, that requirement shall be satisfied if the signature is electronic.”
18. While this Rule is useful in relation to documents produced in Court, we believe a more general
provision in relation to the use of electronic signatures in any document used in ADGM would benefit stakeholders.
19. The Model Law provides the most widely used set of legislative criteria for establishing a
generic functional equivalence between electronic and handwritten signatures. It provides that where a law requires a signature of a person, that requirement is met in relation to a data message if:
(a) a method is used to identify the signatory and to indicate the signatory’s approval of the information contained in the data message; and (b) that method is as reliable as was appropriate for the purpose for which the data message was generated or communicated. Electronic signatures, Contracts and Records

Consultation Paper No. 3 of 2020
20. This provision contemplates the two main functions of handwritten signatures are to identify
the signatory, and to indicate the signatory’s intent with respect to the signed information. Any technology that can perform these two functions in electronic form should, according to the Model Law, be regarded as satisfying a legal signature requirement.
21. Accordingly, the Regulations are technology neutral, as they do not depend on or presuppose
the use of any particular type of technology, and can be applied to the communication and storage of all types of information. Technological neutrality is important given the speed of innovation, and helps to ensure that legislation remains capable of accommodating future developments and does not become obsolete (and in need ofregular amendment). It also puts the onus on the parties to determine the level of security that is adequate for their communications and transactions. Electronic Contracts
22. The fundamental principle under the Model Law is that the medium used to form a contract
should not affect its legal significance. This eliminates the medium as a reason to deny the effect or enforceability of a contract and confirms that contractual offer and acceptance can be expressed via electronic communications. The Regulations go further to negate any potential claim by a party that there is an inherent lack of human intent in relation to contracts formed by automated means. The requisite intention flows from the programming and use of a digital machine involved in contracting. Electronic Records
23. Under the Model Law, laws relating to electronic records need to be consistent with recognised
and established international approaches in markets, adopting a functional equivalent approach to electronic records based on an analysis of the purpose and function of paper￾based documentary requirements.
24. Paper documents fulfil many functions. These include:
(a) providing a record of a transaction or other information; (b) ensuring integrity of the information contained therein by setting out the information in an unaltered form; (c) permitting reproduction of the information, whether for the purpose of sharing the record of agreed terms between two contracting parties or presenting evidence of the information contained in the document; and (d) allowing for authentication by means of a signature, seal or stamp.
25. For all these functions, electronic records can provide the same level of security as paper and,
in most cases, with a much higher degree of reliability and speed, provided that a number of technical and legal requirements are met.
26. Where a provision in any ADGM enactment or subordinate legislation requires information to
be in writing or for information to be delivered or records to be retained, the use, delivery or retention of an Electronic Record will satisfy those requirements. This ensures that information not be denied legal effect solely due to it being in the form of an electronic record.

Consultation Paper No. 3 of 2020
Q2: DO YOU HAVE ANY COMMENTS ABOUT THE PROPOSED SCOPE OF THE REGULATIONS? Q3:ARE THE PROVISIONS OF THE REGULATIONS CLEAR? IF NOT, PLEASE EXPLAIN WHY NOT. Exclusions
27. Taking into consideration the exclusions under the Model Law, ADGM has included a set of
exclusions in the Regulations to best meet the needs of ADGM entities. The exclusions are generally the types of transactions that require secondary witnessing or attestations or which are required under applicable law (for instance, transactions relating to the sale of real property). These include:
(a) the creation, performance or enforcement of a power of attorney; (b) the creation, performance or enforcement of a declaration of a trust (with the exception of implied, constructive and resulting trusts) and any provision in the Trusts (Special Provisions) Regulations 2016 and Foundations Regulations 2017 requiring information to be written or in writing; (c) the creation and execution of wills, codicils or testamentary trusts; (d) transactions involving the sale, purchase, lease (for a term of more than 10 years) and other disposition of immovable property and the registration of otherrights relating to immovable property; (e) any document to be notarised before the notary public; and (f) negotiable instruments, documents of title, bills of exchange, promissory notes, consignment notes, bills of lading, warehouse receipts or any transferable document or instrument that entitles the bearer or beneficiary to claim the delivery of goods or the payment of a sum of money.
28. However, with respect to trusts, while these are excluded in a number of common law
jurisdictions, in ADGM the only requirements for trust-related records to be “in writing” are:
(a) the Trust (Special Provisions) Regulations 2016; section 4(8) requires enforcers to resign office by notice in writing; and (b) Foundations Regulations 2017, which requires by-laws, the Charter, notices and resolutions to be in writing.
29. ADGM does not object to trust documents being made and kept in electronic form and would
recommend this exclusion be removed. However we have retained it in the draft Regulations for the purposes of public consultation.

Consultation Paper No. 3 of 2020
30. Finally, in most jurisdictions, negotiable instruments are excluded from similar legislation.
Given cheques (which are negotiable instruments) are still widely used in the UAE and must be signed in ink, an exclusion for cheques appears necessary.
31. However, ADGM is also aware of the development of digital negotiable instruments in certain
jurisdictions (for instance, electronic letters of credit and bills of lading) to support digitalization of international trade finance, provided the legislative framework facilitates it. Q4: DO YOU HAVE ANY CONCERNS REGARDING THE PROPOSED EXCLUSIONS? IF SO, WHAT ARE THOSE CONCERNS. Q5: DO YOU AGREE TRUST RECORDS SHOULD BE REMOVED FROM THE EXCLUSIONS? Q6:WOULD YOU LIKE TO SEE NEGOTIABLE INSTRUMENTS REMOVED FROM THE EXCLUSIONS? IF SO, WHY? Q7:ARE THERE ANY OTHER MATTERS NOT ALREADY LISTED THAT YOU WOULD LIKE TO SEE EXCLUDED FROM THE REGULATIONS? The “in writing” requirement
32. Currently under ADGM law, section 1(1) of the Interpretation Regulations 2015 provides:
“writing” and expressions referring to writing include printing, lithography, typewriting, photography and other modes of representing or reproducing words or figures in visible form.”
33. ADGM proposes to amend the current definition of “writing” in section 1(1) of the Interpretation
Regulations 2015 to specifically include the use of electronic modes of representing or reproducing words within the definition.This will ensure it is clear the defined term also includes electronic modes of representing or reproducing words. The proposed amendment to the Interpretation Regulations 2015 are set out in Annex B.  Annex A Proposed Electronic Transactions Regulations 2020  Annex B Proposed Interpretation (Amendment No.1) Regulations 2020 PROPOSED AMENDMENTS AND REGULATIONS

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Annex A – Proposed Electronic Transactions Regulations 2020

Annex A
ELECTRONIC TRANSACTIONS REGULATIONS 2020

Annex A
TABLE OF CONTENTS
TABLE OF CONTENTS........................................................................................................... 2
PART 1 ELECTRONIC RECORDS........................................................................................... 3

1. Legal recognition of Electronic Records................................................................... 3
2. Requirement for writing............................................................................................. 3
3. Provision of Information in writing and presentation of Electronic Records ........... 3
4. Conditions for Retention of Electronic Records ....................................................... 3
5. Admissibility of Electronic Records in evidence....................................................... 4
   PART 2 ELECTRONIC CONTRACTS....................................................................................... 5
6. Legal recognition of electronic contracts.................................................................. 5
7. Formation and validity of contracts in an Electronic Communication..................... 5
8. Effectiveness between parties................................................................................... 5
9. Invitation to make an offer......................................................................................... 5
10. Use of automated message systems for contract formation .................................... 5
11. Time and place of despatch and receipt.................................................................... 5
    PART 3 ELECTRONIC SIGNATURES...................................................................................... 7
12. Legal recognition of Electronic Signatures............................................................... 7
13. Validity of Electronic Signatures............................................................................... 7
14. Attribution and effect of Electronic Signature........................................................... 7
15. Admissibility of Electronic Signatures in evidence................................................... 7
    PART 4 EXCLUSIONS............................................................................................................. 8
16. Excluded matters....................................................................................................... 8
17. Exclusion or modification by the parties................................................................... 8
    PART 5 GENERAL PROVISIONS............................................................................................ 9
18. Interpretation of certain words and expressions ...................................................... 9
19. Short title, extent and commencement matters........................................................ 9

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ELECTRONIC TRANSACTIONS REGULATIONS 2020
Regulations to facilitate commerce in the Abu Dhabi Global Market by providing legal validity and certainty to Electronic Records, electronic contracts and Electronic Signatures Date of Enactment: [ ] The Board of Directors of the Abu Dhabi Global Market, in exercise of its powers under section 6(1) of Law No. 4 of 2013 concerning the Abu Dhabi Global Market issued by His Highness the Ruler of the Emirate of Abu Dhabi enacts the following Regulations.
PART 1
ELECTRONIC RECORDS

1. Legal recognition of Electronic Records
   (1) Information in the form of an Electronic Record has legal effect, validity or enforceability as if it were in writing.
2. Requirement for writing
   (1) Where a provision in an Enactment requires Information to be in writing, or provides for certain consequences if Information is not in writing, an Electronic Record satisfies that provision if it preserves a record of the Information and can be reproduced in tangible form.
3. Provision of Information in writing and presentation of Electronic Records
   (1) If parties have agreed to conduct a transaction by Electronic means and a provision in an Enactment requires a person to provide, send, or deliver Information in writing to another person, the requirement is satisfied if the Information is provided, sent, or delivered, as the case may be, in an Electronic Communication capable of retention once it is received. (2) For the purposes of subsection (1) above, Information is not capable of retention if the Originator or the Originator’s Information System inhibits the ability of the Addressee to reproduce the Information in tangible form or retain the Electronic Communication. (3) If an Originator inhibits the ability of an Addressee to reproduce the Information in tangible form or retain an Electronic Record, the Electronic Record is not enforceable against the Addressee.
4. Conditions for Retention of Electronic Records
   (1) Where an Enactment requires a Record to be retained, or provides for certain consequences if it is not retained, that requirement is satisfied by retaining the Record

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in an Electronic Record if the following conditions are satisfied:
(a) the Electronic Record preserves a Record of the Information it contains and is capable of being reproduced in tangible form; (b) the Electronic Record is retained in the format in which it was originally created, or in a format which can be demonstrated to accurately replicate the original Information; (c) the Information enables the identification of the origin and destination of the Electronic Record, any party that sent or received the Electronic Record; (d) the date and time the Electronic Record was sent or received; and (e) any additional requirements relating to the retention of such Electronic Records specified in an Enactment are complied with. (2) Section 4(1) does not extend to the Electronic Communication used to send or receive it. (3) A person may satisfy the requirements referred to in section 4(1) by using the services of a third party, if the conditions in sections 4(1)(a) to (d) are complied with. (4) If a provision set out in an Enactment requires a Record to be presented or retained in its original form, or provides for certain consequences if the Record is not presented or retained in its original form, that provision is satisfied by an Electronic Record retained in accordance with section 4(1) unless the Enactment expressly prohibits the use of an Electronic Record for the specified purpose. (5) If a provision set out in an Enactment requires the retention of a cheque, that requirement is satisfied by retention of an Electronic Record of the Information on the front and back of the cheque, in accordance with section 4(1). (6) A Record retained as an Electronic Record in accordance with section 4 (1) satisfies an Enactment requiring a person to retain a Record for evidentiary, audit, or similar purposes, unless the Enactment expressly prohibits the use of an Electronic Record for the specified purpose.
5. Admissibility of Electronic Records in evidence
(1) An Electronic Record may be used as evidence of a Record in any Court proceedings.

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PART 2
ELECTRONIC CONTRACTS
6. Legal recognition of electronic contracts
(1) An Electronic Record of a contract is of legal effect, valid and enforceable as if it was in writing.
7. Formation and validity of contracts in an Electronic Communication
(1) In the context of the formation of contracts, an offer and the acceptance of an offer may be expressed in an Electronic Communication. (2) Where an Electronic Communication is used in the formation of a contract, that contract has the same legal effect, validity or enforceability as if it was in writing.
8. Effectiveness between parties
(1) Where an Electronic Communication is used for a declaration of intent or other statement, it will have the same legal effect, validity or enforceability as if it was made in writing.
9. Invitation to make an offer
(1) A proposal to conclude a contract made through Electronic Communications that is not addressed to any specific Addressee and is generally accessible to the public, including on a webpage, is to be considered as an invitation to make offers.
10. Use of automated message systems for contract formation
(1) A contract is capable of being formed by the interaction of an automated message system and a natural person, or by the interaction of automated message systems.
11. Time and place of despatch and receipt
(1) Unless otherwise agreed between the Originator and the Addressee, the time of despatch of an Electronic Communication is the time when it leaves an Information System under the control of the Originator or of the party who sent it on behalf of the Originator. (2) Unless otherwise agreed between the Originator and the Addressee, the time of receipt of an Electronic Communication is the time when the Electronic Communication becomes capable of being retrieved by the Addressee at an electronic address designated by the Addressee. (3) Unless otherwise agreed between the Originator and the Addressee, an Electronic Communication is deemed to be despatched at the place where the Originator has its place of business and is deemed to be received at the place where the Addressee has its

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place of business.
(4) Section 11(3) applies even if the place where the Information System supporting an electronic address is located in a place that may be different from the place where the Electronic Communication is deemed to be received under section 11(3). (5) Nothing in this section will affect the deemed time for the service of documents under the ADGM Court Procedure Rules 2016, or any deeming provisions for the service of documents contained in an Enactment.

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PART 3
ELECTRONIC SIGNATURES
12. Legal recognition of Electronic Signatures
(1) Where an Enactment requires the signature of a person, or provides for certain consequences if a document or a Record is not signed, that provision is satisfied if an Electronic Signature is used, unless the Enactment expressly prohibits the use of an Electronic Signature.
13. Validity of Electronic Signatures
(1) An Electronic Signature is deemed to identify the relevant person and to indicate that person’s intention to sign the Record, provided that the type of Electronic Signature used is, either:
(a) reliable and appropriate for the purpose for which the Record was generated or communicated, in light of all the circumstances, including any relevant agreement between the parties; or (b) proven to have fulfilled the functions described in paragraph (a) above, by itself or together with further evidence.
14. Attribution and effect of Electronic Signature
(1) An Electronic Signature is attributable to a person if the act of the person can be demonstrated, including through the efficacy of any security procedure used, to determine the person to which the Record the subject of the Electronic Signature is attributable. (2) The effect of an Electronic Signature attributed to a person under section 14(1) is determined from the context and surrounding circumstances at the time of its creation, execution, or adoption, including the parties’ agreement, if any, and otherwise as provided by any applicable law.
15. Admissibility of Electronic Signatures in evidence
(1) In any proceedings before the Court, evidence of a signature includes an Electronic Signature.

Annex A

PART 4
EXCLUSIONS
16. Excluded matters
(1) The provisions of Parts 1, 2 and 3 of these Regulations do not apply to any provision set out in an Enactment or any applicable law requiring writing or signatures in any of the following matters:
(a) the creation, performance or enforcement of a power of attorney; (b) the creation, performance or enforcement of a declaration of trust (with the exception of implied, constructive and resulting trusts) and any provision in the Trust (Special Provisions) Regulations 2016 or the Foundations Regulations 2017 requiring Information to be written or in writing; (c) the creation and execution of wills, codicils or testamentary trusts; (d) transactions involving the sale, purchase, lease (for a term of more than 10 years) and other disposition of immovable property and the registration of other rights relating to immovable property; (e) any document to be notarised before a notary public; (f) subject to section 4(5), negotiable instruments, documents of title, bills of exchange, promissory notes, consignment notes, bills of lading, warehouse receipts or any transferable document or instrument that entitles the bearer or beneficiary to claim the delivery of goods or the payment of a sum of money.
17. Exclusion or modification by the parties
(1) The parties to a contract or transaction may expressly exclude, derogate from or vary the application of any provisions of these Regulations unless an Enactment or any applicable law otherwise provides. (2) The parties to a contract or transaction may impose additional requirements to the form or authentication of the contract or transaction by agreement unless an Enactment or any applicable law otherwise provides.

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PART 5
GENERAL PROVISIONS
18. Interpretation of certain words and expressions
(1) In these Regulations:
“Addressee” in relation to an Electronic Communication, means the party who is intended by the Originator to receive the Electronic Communication. “Court” means any of the courts established pursuant to Article 10 of the ADGM Founding Law. “created” includes generated, sent, communicated, or received. “Electronic” relates to technology having electrical, digital, magnetic, wireless, optical, electromagnetic, or similar capabilities. “Electronic Communication” means any communication made by means of Electronic Records. “Electronic Record” means a Record created, generated, sent, communicated, received or retained in Electronic form. “Electronic Signature” means an Electronic sound, symbol or process attached to or logically associated with a Record and executed or adopted by a person with the intent to sign the Record. “Enactment” means an “enactment” or “subordinate legislation”, within the meaning given to these words in the Interpretation Regulations 2015. “Information” includes data, text, images, sounds, codes, computer programs, software, databases, symbols or processes. “Information System” means a system for generating, sending, receiving, storing or otherwise processing Electronic Records. “Originator” in relation to an Electronic Communication, means the party who sent the Electronic Communication. “Record” means Information that is capable of retention in either tangible or Electronic form.
19. Short title, extent and commencement
(1) These Regulations may be cited as the Electronic Transactions Regulations 2020. (2) These Regulations shall apply in the Abu Dhabi Global Market.

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(3) These Regulations shall come into force on the date of their publication.

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Annex B – Proposed Interpretation (Amendment No. 1) Regulations 2020

Annex B
INTERPRETATION (AMENDMENT No.1) REGULATIONS 2020

Annex B
INTERPRETATION (AMENDMENT No.1) REGULATIONS 2020 Regulations amending the Interpretation Regulations 2015 Date of Enactment: [ ] 2020 The Board of Directors of the Abu Dhabi Global Market, in exercise of its powers under Article 6(1) of Law No. 4 of 2013 (as amended), concerning the Abu Dhabi Global Market issued by His Highness the Ruler of the Emirate of Abu Dhabi, hereby enacts the following–

1. Amendment to the Interpretation Regulations 2015
   PART 1
   GENERAL PROVISIONS OF INTERPRETATION
2. Interpretation of certain words and expressions
   (1) In these Regulations, in every enactment (whenever enacted) and in any subordinate legislation (whenever adopted), the following words and expressions shall have the meanings respectively assigned to them unless there is something in the subject or context inconsistent with such construction or unless it is therein otherwise expressly provided:
   ….
   “writing” and expressions referring to writing include printing, lithography, typewriting, photography and other modes of representing or reproducing words or figures in visible or electronic form; and
3. Short title, extent and commencement
   (1) These Regulations may be cited as the Interpretation (Amendment No.1) Regulations 2020. (2) These Regulations shall apply in the Abu Dhabi Global Market. (3) These Regulations come into force on the date of their publication.